Count one:
That you Nnamdi Kanu, male adult of Afaraukwu lbeku Umahia North Local Government Area of Abia State being the leader of the Indigenous People of Bialra (IPOB) on diverse dates in 2014 and 2015 in London, United Kingdom, did broadcast on Radio Biafra monitored in Enugu and other areas within the jurisdiction of this Honourable Court, preparations made by you and others now at large for states in the South-East and South-South zones and other communities in Kogi and Benue States to secede from the Federal Republic of Nigeria with a view to constituting same into the Republic of Biafra and you thereby committed an offence punishable under Section 41(c) of the Criminal Code Act, CAP. C77, Laws of the Federation of Nigeria, 2004.
Count two:
That you Nnamdi Kanu, male, adult, of Afaraukwu Ibeku, Umuahia North Local Government Area ot Abia State, on or about the 28th April, 2015 in London, United Kingdom did broadcast on Radio Biafra monitored in Enugu, Enugu State and other parts of Nigeria within the jurisdiction of this Honourable Court, referred to Major General Muhammadu Buhari, GCON, the President and Commander-in-Chief of the Armed Forces of the Federal Republic of Nigeria as a paedophile, a terrorist, an idiot and an embodiment of evil, knowing same to be false and you thereby committed an offence contrary to Section 375 of the Criminal Code Act, Cap C. 77, Laws of the Federation of Nigeria 2004.

Count Three:

That you Nnamdi Kanu, male adult of Afaraukwu lbeku Umahia North Local Government Area of Abia State between the month of March and April 2015 imported into Nigeria and kept in Ubulusiuzor in Ihiala Local Government Area of Anambra state within the jurisdiction of this Honourable Court , a Radio transmitter known as TRAM 50L concealed in a container of used household which you declared as used household items and you thereby committed an offence contrary to Section 47 (2) of the Criminal Code of Act ,Cap C45, Laws of the Federation of Nigeria, 2004.
Count four

That you Nnamdi Kanu, male, adult. of Afaraukwu iIbeku, Umuahia North Local Government Area of Abia State in London, United Kingdom between 2018 and 2021 Radio Biafra monitored in Enugu, Enugu State and FCT, Abuja within the jurisdiction of this Honourable Court, professed to be a member of Indigenous People of Biafra (IPOB), a proscribed organisation in Nigeria and you thereby committed an offence punishable under Section 16 Terrorism Prevention Amendment Act, 2013.
Count five:
That you Nnamdi Kanu, male, adult, of Afaraukwu Ibeku, Umuahia North Local Government Area of Abia State on the 22th of April, 2021 in London, United Kingdom on Radio Biafra monitored in Enugu, Enugu State and other parts of Nigeria within the jurisdiction of this Honourable Court did an act of terrorism in that you incite the other members (followers) of the Indigenous People of Biafra (IPOB}, a proscribed organisation in Nigeria, to look for security personnel, their family members through a Radio Biafra on 102.1FM monitored through the IPOB Community Radio and you thereby committed an offence contrary to and punishable under Section 1 (2) (h) of the Terrorism Prevention Amendment Act.
Count six:
That you Nnamdi Kanu, male, adult, of Afaraukwu Ibeku, Umuahia North Local Government Area of Abia Stale on the 16thh of May, 2021, in London, United Kingdom within the jurisdiction of this Honourable Court did commit an act in furtherance of an act of terrorism by making a broadcast that “In 2 weeks’ time, what will happen will shake the world, people will die, the whole world will stand still, mark my word” and you thereby committed an offence contrary to and punishable under Section 1 (2) (b) of the Terrorism Prevention Amendment Act, 2013.
Count seven:
That you Nnamdi Kanu, male, adult, of Afaraukwu Ibeku, Umuahia North Local Government Area of Abia State on the 31st of May, 2021, in London, United Kingdom within the jurisdiction of this Honourable Court did an act in furtherance of an act of terrorism by issuing a deadly threat that anyone who flouted your sit-at-home order should “write his/her will,” as a result banks, schools, markets, shopping malls, fuel stations were not opened for businesses and vehicular movements grounded and you thereby committed an offence contrary to and punishable under Section 1 (2) (b) of the Terrorism Prevention Amendment Act, 2013.
